Office of Foreign Assets Control

News & Analysis as of

DOJ Fines Bank Record $9 Billion for OFAC Sanctions Violations

The U.S. Department of Justice (DOJ) recently sent a strong message to international banks with a record penalty of nearly $9 billion on one of the world's largest banks for violating U.S. sanctions against Sudan, Cuba and...more

AML BSA and Sanctions Compliance Part II of II June 24, 2014  [Video]

The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial...more

AML BSA and Sanctions Compliance I of II June 10 2014 [Video]

The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial...more

United States and European Union Ratchet Up Russia Sanctions

On July 16, 2014, the United States ratcheted up its sanctions on Russia in connection with escalating tensions in Eastern Ukraine. Specifically, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”)...more

New Ukraine-Related Sanctions Imposed on Russian Interests

On July 16, 2014, the Obama Administration responded further to developments in Ukraine by imposing another new round of sanctions on Russian, Ukrainian and Crimean parties. Importantly, for the first time, the United States...more

United States Imposes New Sanctions and Export Restrictions Against Russian Banks, Companies, and Individuals

On July 16, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed new sanctions against Russia, which target the country’s financial, energy and defense sectors. In a parallel action, the U.S....more

Ukraine Crisis Update: US Imposes New Sanctions on Major Russian Banks and Energy Companies

US announces “sectoral” sanctions on major banks and energy companies, adds to the Specially Designated Nationals list; European Council considers additional sanctions. On July 16, 2014, the U.S. Department of the...more

Obama Beefs Up Russian Sanctions, But Still No Full Monty

President Obama announced yesterday the creation of the new Sectoral Sanctions Identification List (“SSI List”) issued pursuant the Russian sanctions program and the addition of two Russian energy companies and two Russian...more

Fifth Round of Sanctions Target Certain Russian Banks, Energy Companies and Arms Manufacturers

The U.S. Office of Foreign Assets Control (OFAC) issued a fifth round of designations imposing limited sanctions on two Russian banks and two major Russian energy companies. OFAC also designated and blocked the assets of...more

US Imposes Sectoral Sanctions on Russian Financial and Energy Companies, Expands Ukraine-Related Designations and Adds Further...

On July 16, 2014, the United States issued new sanctions targeting the Russian financial and energy sectors in response to the ongoing unrest in Ukraine. The new sectoral sanctions target four Russian companies by placing...more

Don’t try this at Home or Abroad: Export Controls and Sanctions Violations Lead to $21 Million in Penalties for Dutch Company...

We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more

CBP Releases Eligibility Requirements and Security Criteria for its C-TPAT Exporter Program

On July 9, 2014, U.S. Customs and Border Protection (CBP) released the eligibility requirements and security criteria for its expanded Customs-Trade Partnership Against Terrorism (C-TPAT) program. CBP is expanding C-TPAT to...more

Big Bank gets Spanked to the Tune of $9 Billion

Last week French bank BNP Paribas (BNPP) became the latest financial institution to be penalized for violating the OFAC sanctions programs. BNPP was accused of processing thousands of transactions through U.S. banks for...more

It’s Not Rocket Science: Taking the Steps Necessary to Avoid Costly Sanctions Violations

The $963 million settlement OFAC recently reached with French banking giant BNP Paribas SA (BNP) was both the largest OFAC settlement to date and represents only a small fraction of the nearly $9 billion in total fines...more

Red Notice Newsletter - June 2014

Welcome to the June 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month, on the anticorruption front, the U.S. Court of Appeals for the 11th Circuit defines key Foreign Corrupt...more

FDIC Restricts Bank’s Card Businesses Pending BSA Compliance Enhancements

On June 5, the FDIC and a Delaware bank entered a consent order that prohibits the bank from entering into any new relationships with third-party prepaid card processors or prepaid card program managers until the FDIC...more

The United States Designates Seven Individuals Under Executive Order 13660 Relating to Separatist Activity in Ukraine

On June 20, 2014, the US Office of Foreign Assets Control (“OFAC”) issued further designations under Executive Order 13660 (“EO 13660”). EO 13660, which was signed on March 6, 2014, authorizes the United States to impose...more

FinCrimes Update - Volume 1, Issue 3

On May 8, OFAC released enforcement information regarding “apparent violations” of the Cuban Assets Control Regulations by Canadian subsidiaries of a U.S. insurance company. The U.S. company self-reported 3,560 apparent...more

Treasury Department Announces $21 Million Resolution Of Alleged Iran and Sudan Sanctions Violations

On June 5, the Treasury Department’s Office of Foreign Assets Controls (OFAC) announced a Dutch aerospace firm has agreed to pay $21 million to resolve allegations that the company violated U.S. sanctions on Iran and Sudan....more

Red Notice Newsleter

Welcome to the May 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month, on the anticorruption front, Avon Products, Inc. (“Avon”) agrees to pay USD $135 million to settle a...more

AML/BSA Compliance Program Best Practices

I am always wary of definitive “best practices” lists. By definition, “best practices” vary depending on the size and nature of an organization in any compliance context....more

FinCEN Advisory Addresses Risks Presented By Citizenship-by-Investment Program

On May 20, FinCEN issued Advisory FIN-2014-A004, warning financial institutions about the risk of illicit financial activity conducted by individuals with passports from St. Kitts and Nevis (SKN), which allows individuals to...more

New Beginnings

Benjamin Franklin once said that no nation was ever ruined by trade. While that may be true, those of us in the private sector have seen our kind ruined by failures in trade law compliance far too often. Let’s be honest:...more

Practical Guidance for Dealing with OFAC’s Recently Released Ukraine Related Sanctions Regulations and the EU’s Ukraine Sanctions

On May 8, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued regulations to implement three Executive Orders issued by President Obama in March regarding the situation in Ukraine. The...more

Western Sanctions Expand as Tension in Ukraine Continues

The United States, Canada and the European Union have designated a number of additional officials and companies as the unrest continues in eastern Ukraine. The United States also imposed sanctions on the head of Russian...more

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